The Allergen Bureau continues to receive enquiries about applying the VITAL® Program to bulk products and ingredients not sold directly to consumers.
The VITAL Program is applicable to bulk products and ingredients, as it provides a consistent, science-based framework to assess and manage allergen cross contact. These suppliers should conduct a full VITAL® risk assessment, identifying and quantifying any residual allergen cross contact remaining after all reasonable measures to eliminate or reduce it have been applied.
However, Action Level calculations are not applicable to bulk products or ingredients intended for further processing, as a Reference Amount cannot be defined. In this case, suppliers should select the ingredient for further processing option.
Reference Amounts are critical to determining Action Levels, and therefore impact labelling outcomes and consumer risks. Therefore, they must only be applied by the packaged food manufacturer, who holds the necessary knowledge of the product’s composition, category, target market and intended use, and is responsible for accurate labelling.
Suppliers should instead:
- Identify any particulate cross contact allergens, and
- Provide the total concentration of any readily dispersible cross contact allergens.
This information allows manufacturers of packaged consumer products to incorporate the data into their own VITAL® assessments to determine labelling outcomes.
Action Levels can be used for internal risk assessment to explore “what if” scenarios or to understand how predicted allergen levels might impact labelling outcomes. However, they must never be used in place of providing accurate, measured and verified data on the actual allergen status of an ingredient or bulk product.
This information has been captured in VITAL FAQ section of our website.
